What challenges should you expect to have to overcome implementing the AML/CFT Program?
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There are a number of challenges to be overcome, below is a (non-exhaustive) list:
- General lack of awareness of AML/CFT laws
- Lack of understanding about how to conduct an effective ML/FT risk assessment
- Lack of knowledge to develop an AML/CFT Program
- Limited time and money to achieve AML compliance
- Lack of available external expert AML resources
- Significant number of new policies and procedures
- Lack of experience in managing regulatory requests
- Estimating the resource requirements to deliver
- Transitioning from project delivery to BAU operations
- Lack ability of keeping AML program current
- Lack of understanding of how to comply with AML
- Lack of skilled and experienced in-house resources
- Complex operating environments
- Significant number of system changes to implement
- Training all staff on ML/FT risks
- Lack of understanding of what is a a key risk role
- Lack of awareness of AML solution providers
- Lack of engagement from staff and management
- Ability to evidence compliance with rules
- Ability to manage the risk of non-compliance
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